CTMA 2015 HM-250 and HM-215M Update Regulatory Changes from DOT

Dates to Remember Final Rule HM-250 Final Rule HM-215M Published on July 11, 2014 Effective Date: October 1, 2014 Delayed Compliance Date: July 13, 2015 Final Rule HM-215M Published on January 8, 2015 Effective Date: January 1, 2015 Delayed Compliance Date: January 1, 2016

Which is Which? HM-250 HM-215M Final Rule that primarily harmonizes with 2009 IAEA TS-R-1 for the transportation of radioactive materials Final Rule that harmonizes with the international standards (ICAO and IMDG) mainly for non-radioactive requirements

173.401(b)(4) and (5) Scope When is radioactive material not Class 7? Modified language in paragraph (b)(4) concerning naturally occurring radionuclides Added a new paragraph (b)(5) establishing that objects with contamination are not regulated if levels do not exceed the definition of contamination in 173.403

Definitions in 173.403 Contamination – minor wording changes Criticality Safety Index – added “conveyance” Exclusive Use – can only use when required Fissile Material – clarified and added reference to the exceptions in 173.453

Definitions in 173.403 Low Specific Activity Radiation Level Mainly revised for clarity Non-fissile or fissile excepted in the opening paragraph Radiation Level Clarifies that it is the sum of all types of ionizing radiation present

173.433 Revisions to the requirements for calculating A1 and A2 values for unlisted radionuclides Added “or no relevant data…” in (b) to help us with using the Tables Rewording of (c) has some unintended consequences Corrected references for symbols in (d) Radioactive contents in Table 7 has been reworded to more closely align with the TS-R-1

Limited Quantity 173.421 Formatting changes: re-designation of the paragraphs Unfortunately these are not properly referenced in the following sections: SP 369 173.4(b) 173.423(a)(2) 173.426(c) 173.428(a)

New Proper Shipping Name UN3507 Uranium Hexafluoride, Radioactive Material, excepted package Class 8 (7) Only for 0.1 kg or less Uranium Hexafluoride Must meet the requirements for Ltd. Qty. 173.421 Ripple effects: Addition of Special Provision 369 Minor changes to 173.2a Changes to 173.420(d)

Packaging General Design Requirements in 173.410 For air shipments, internal pressure differential is not less than maximum normal operating pressure + 95 kPa Industrial Packages in 173.411 Clarifies the use of portable tanks in (b)(4) Clarifies the use of cargo tank/tank car in (b)(5) Revised 1 year document retention to 2 years in (c)

Type A Packaging 173.412(f) pressure changed from 25 kPa (3.6 psi) to 60 kPa (8.7 psia)

Type A Packaging 173.415(a) Revision of the document retention period from 1 year to 2 years (after January 1, 2017) Rewritten to describe (at length) the two options for document retention Full description of packaging and testing or Certification from the packaging manufacturer

LSA/SCO Transport Requirements 173.427(a) For Exclusive Use LSA/SCO 173.427(a)(6) The “shipment” must be placarded (instead of the “transport vehicle”) Removed the placarding exception for uranium and thorium ores Subsidiary hazard labels required (even though primary label is not)

LSA/SCO Transport Requirements 173.427(b) Paragraph (b)(5) Portable Tanks, Cargo Tanks, Tank Cars meeting the requirements for Type IP-1 can be used as Type IP-2 or Type IP-3 (173.411) Not limited to LSA-I liquids No longer required to be exclusive use References to DOT tanks removed

LSA/SCO Transport Requirements 173.427(c) Paragraph (c)(4) New paragraph requiring placarding for all unpackaged LSA-I/SCO-I by highway and rail

LSA/SCO Transport Requirements 173.427 Tables New third column for inland waterway conveyance limits Table 6 Added “Type” to all IP descriptions

Excepted Package Marking 173.422(a)(2) RQ for any non-bulk excepted package containing a hazardous substance

Specification Marking 172.310(b) Package Type Marking size requirement 12mm (0.47 inches) Type IP-1, Type IP-2, Type IP-3 Type A Type B(U), Type B(M)

173.25 Overpack HM-250 added that overpacks containing radioactive packages must be marked with the word “OVERPACK” HM-215M removed the radioactive packages (inadvertently?) but added a minimum size requirement of 12mm (0.5 inches) high

Radioactive Label Maximum activity of the radioactive contents during transport 172.403(g)(2)

LSA/SCO Subsidiary Label Although excepted from radioactive labels (for the primary hazard), LSA/SCO exclusive use must be labeled for any subsidiary hazards per 173.427(a)(6)(vi) Ripple effect: subsidiary hazard will now be required as a shipping paper entry

Shipping Papers 172.203(d) Additional description requirements “Special Form” if not already in the proper shipping name Maximum activity of the radioactive contents during transport Label category does not require “RADIOACTIVE”

172.504 Placarding Radioactive placards are required on Packages with Yellow-III labels All shipments of unpackaged LSA-I/SCO-I All exclusive use shipments in 173.427 All exclusive use shipments in 173.441 All exclusive use shipments in 173.457 Closed vehicles used in accordance with 173.443(d)

Contamination Control 173.443 This section previously addressed only external contamination on a package Now included is the external surface on a Package Conveyance Freight container Overpack Plus the internal surfaces when used to transport inner packages

Contamination Control 173.443 (a) All contamination must be kept As Low As Reasonably Achievable (ALARA) Levels may not exceed Table 9 EXCEPT for Equipment dedicated to transport unpackaged material in accordance with 173.427(c) and Remain under that specific exclusive use Non-exclusive use shipments are not required to be surveyed unless contamination is suspected

Contamination Control 173.443 (a) and (b) Table 9 Limits: Corrected the conversion from bq/cm2 to dpm/cm2 using SI units instead of customary units Reworded (b): Still allows for 10 times Table 9 limits during transport and must be exclusive use (“weeping” condition)

Contamination Control 173.443 (c) Each conveyance, overpack, freight container, tank or IBC used as exclusive use under the following conditions must be surveyed with appropriate radiation detection instruments after each shipment: 173.443(b) the “weeping” condition 173.427(b)(4) LSA/SCO, <A2, in excepted packaging 173.427(c) unpackaged LSA-I and SCO-I

Contamination Control 173.443(c) The survey must show that non-fixed contamination meets 173.443(a) ALARA Does not exceed Table 9 limits The radiation level at each accessible surface is ≤ 0.5 mrem/hr

Contamination Control 173.443(c) Meeting these survey requirements ONLY allows for continued exclusive use of the equipment as one of the following: 173.443(b) the “weeping” condition 173.427(b)(4) LSA/SCO, <A2, in excepted packaging 173.427(c) unpackaged LSA-I and SCO-I

Contamination Control 173.443(c) The ONLY way to utilize the aforementioned exclusive use shipment types for non-exclusive use or general service is: Perform decon on the equipment as necessary and Any contamination is determined to be below the limits in 173.401(b)(5) and below the definition of contamination in 173.403

Contamination Control 173.443(d) “Sole Use” allows up to 10 times the Table 9 limits for vehicles used under the following conditions Exclusive use by highway or rail Survey of interior surfaces of empty vehicle ≤ 10 mrem/hr surface ≤ 2 mrem/hr at 1 meter “For Radioactive Materials Use Only” stenciled Kept closed (except for loading and unloading) Placards required

Contamination Control 173.443(e) New paragraph for leaking or suspect packages Restrict access Assessment of the contamination must include The package The conveyance Adjacent loading/unloading areas All other materials carried on the conveyance Protect persons, property, environment Not forwarded until repaired/decontaminated

Contamination Control Added similar language for surveys and re-use to all modes of transport Carriage by Rail in 174.715 Carriage by Aircraft in 175.705 Carriage by Vessel in 176.715 Carriage by Public Highway in 177.843

HM-215M : “Timing is Everything” Important to note: Because this rule was published AFTER October 1, 2014 it is not in the current 49 CFR (unless you use regulations that are updated quarterly) This Final Rule must be consulted in addition to the current 49 CFR if you are complying with HM-215 in 2015 and especially after January 1, 2016

Definitions 171.8 New or revised Absorbed gas Bundle of cylinders Large salvage packaging Neutron radiation detector Non-bulk packaging Radiation detection system

171.23(b)(11) Requirements for specific materials transported under ICAO, IMDG, TDG or IAEA Fissile excepted materials must meet IAEA SSR-6 regulations and 173.453

Proper Shipping Names Ten shipping names were removed Dozens have been added Pages and pages of entries were revised Largely due to changes in Column 10 for IMDG harmony

List of Marine Pollutants Addition of 62 new entries New exception for 5 liters (liquids) and 5 kg (solids) if regulated only because they are a marine pollutant

Special Provisions 172.102 Safety devices (automotive parts) Neutron Detectors Absorbed gases Paint/paint related material in same package Uranium Hexafluoride IBC Codes

Shipper’s Certification Above = Below “This is to certify that the above- named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.” Note: In the certification the word “above” may be substituted for the word “below” as appropriate.

Exceptions for Light Bulbs 173.11 No other requirements if: 1 g or less of hazardous material per bulb 30 g or less of hazardous material per package Each bulb in separate inner packaging Strong tight outer (173.24(b)) Capable of passing a 1.2 m (4 foot) drop test

Explosives Table of Packing Methods Changes to some packing methods Always consult the table

Lithium Cells and Batteries 173.185 Added Large Packaging requirements Allows for the Cargo Aircraft Only Label to substitute for the lithium battery marking

Questions? Thank You